The beneficial ownership concept has constituted for more than half a century one of the most fundamental and debated issues in the application of tax treaties. This article goes back to routes of this term explaining the reason of its original inclusion in the OECD Model Tax Convention and why ultimately such inclusion may have not been necessary. Then it analyses the historical developments of beneficial ownership in the OECD Model Tax Convention. For that purpose it considers different interpretations adopted by jurisdictions (particularly in China) and local courts delving into some of the landmark cases on the subject. Finally it provides a detailed analysis of the current meaning of beneficial ownership considering the most recent developments in the Commentary to the OECD Model Tax Convention.
In his book Time in Ruins, the French anthropologist Marc Augé pointed out that “humanity is not in ruins, it is being built.” These words well fit both the present-day Chinese context and the figurative trend of new shanshuihua in which construction sites, cityscapes and artificial nature territories become the subject of depiction. New iconic elements that provide a visual and conceptual framework for artists’ construction of a different shanshui-type heavily indebted to Chinese social and environmental changes, these new coded depictions substitute the traditional representation of natural landscape, reflect the rise of a new sensibility about nature and challenge the idea of what landscape is in the context of Chinese contemporary art. By focusing on a variety of works related to the theme of artificial nature and representing paradigmatic images of physical and allegorical landscape, this paper aims to explore this visual and conceptual innovations introduced in the context of new shanshuihua and analyze the way in which artists use nature, trying to find a new aesthetic categorization for this artistic genre.